Annual review FIU - the Netherlands 2022
On June 29, 2023, the Minister of Justice and Security presented the 2022 Annual Review of the Financial Intelligence Unit the Netherlands (FIU-Nederland) to the Members of the House of Representatives.
You can consult our annual review here.
FIU-the Netherlands is designated in the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) as the authority to which unusual transactions must be reported by institutions obliged to report. FIU-the Netherlands analyzes these reports and identifies transactions and financial flows that can be linked to money laundering and underlying offenses as well as the financing of terrorism. Unusual transactions declared suspicious by the head of FIU-the Netherlands are made available to the various (special) investigative services and intelligence and security services at home and abroad. FIU-the Netherlands thus fulfills an important role in the prevention and detection of crime.
The width of the Wwft-domain
The Annual Review 2022 shows that the trend of the increasing number of unusual transactions reported by obliged entities continues this year. In total, almost two million unusual transactions were reported by 1,953 different institutions. We would like to highlight that last number in particular. There are nearly two thousand institutions that made at least one report last year. Ranging from brokers, accountants, and virtual assets service providers to trust offices, banks and casinos. In total, there are currently 29 different types of obliged entites. A fact sometimes overlooked in our view, this width of the Wwft-domain.
FIU-the Netherlands declared 91,893 transactions suspicious in 2022, divided into 16,213 case files. These were made available to the (special) investigation agencies and intelligence and security services. The total value of these transactions amounted to almost thirty billion euros. In the annual review, we address the nuance which is so important with these kinds of figures. It is also important to note that this amount cannot be equated with a possible seizure result of the same magnitude in the Netherlands. This is because suspicious transactions largely involve cross-border financial flows. Think of internationally operating criminals, but also money flows that use our highly international financial system without these flows having any further link to the Netherlands. Very valuable financial intelligence can emerge from these types of international financial flows though. In some cases, we even focus specifically on this. A good example from 2022 is our work on sanction evasion.
Intentional evasion of sanctions is a crime under the Economic Offenses Act (WED) and thus a predicate offense for money laundering. In other words, transactions involving sanctions may also potentially be unusual transactions within the meaning of the Wwft. Therefore, from the moment it became clear that the sanctions package was coming, a number of FIU analysts focused specifically on this issue. The great advantage of FIU-the Netherlands’ position here is that our database goes back five years. The analysts were therefore able to apply their new knowledge to five years of transaction data. This revealed valuable insights. Partly on this basis, we sent out a newsletter in March 2022 to obliged entities that included a number of possible risks. Of course, throughout this process, close cooperation was sought with partners such as the (special) investigative agencies, the Public Prosecution Service, various ministries and foreign FIUs.
On the private side, we also noticed a strong scaling up. Many requests came in for knowledge sessions to which we responded where possible. A good example is the webinar from the Financial Expertise Center (FEC) in March in which more than four hundred professionals came together to be updated on this topic and in which we as FIU-the Netherlands were both speakers and listeners. In the end, all this led not only to knowledge sharing and joint knowledge development, but also to some very concrete results. A total of 137 case files were declared suspicious on this topic, containing 2,721 suspicious transactions on various sanctions-related matters. For example, we were informed by a partner FIU that, partly on the basis of our information, shipments of so-called dual-use goods (1) were intercepted before they could be shipped. A very valuable result. And also domestically, the increased attention to sanctions led to great results. For example, in one investigation the FIOD was able to seize 137 million euros (2) and in another investigation it was able to make an arrest in connection with a sanctions violation involving microchips. (3)
The power of financial intelligence
These examples again demonstrate the power of the Wwft-chain. In an earlier annual review, this was already very evident in the process surrounding the misuse of Covid-19 support funds. Now it is showing again. The Wwft-chain and the fiancial intelligence resulting from it is of great importance in countering money laundering, underlying crimes and terrorist financing. Every single day. Sometimes it is so obvious. But in a ”new” situation where we as a chain have to move quickly to both learn from each other and to counter crimes, it is now proving once again how powerful the Wwft-domain can be.
Of course, this does not mean that we are already there. There is always room for improvement. Therefore, in the annual review we go through a number of measures following the results of the various evaluations published in 2022. For example, measures aimed at being able to steer even better towards desired outcomes. Taking decisive action on the outcomes of the evaluations is essential to taking the next step. As a chain, but certainly also as FIU-the Netherlands.
January 16, 2024
As of January 1st 2024, FIU-the Netherlands stopped with its traditional newsletter to obliged entities.
October 24, 2023
Starting today, reports of unusual transactions made based on the subjective indicator without a transaction description will be rejected.
August 3, 2023
Last week, FIU-the Netherlands visited the Financial Crime Enforcement Network (FinCEN). Our American counterpart, FinCEN is both the US FIU and the AML/CFT supervisor in one. The working visit was all about sharing knowledge and expertise and strengthening cooperation.